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Reassessing 'Carter-Case' Spending for Students with Disabilities in New York City Schools

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Title: Reassessing 'Carter-Case' Spending for Students with Disabilities in New York City Schools
Language: English
Authors: Jennifer Weber, Manhattan Institute (MI)
Source: Manhattan Institute for Policy Research. 2026.
Availability: Manhattan Institute for Policy Research. 52 Vanderbilt Avenue, New York, NY 10017. Tel: 212-599-7000; Fax: 212-599-3494; Web site: http://www.manhattan-institute.org
Peer Reviewed: N
Page Count: 20
Publication Date: 2026
Document Type: Reports - Evaluative
Descriptors: Equal Education, Educational Legislation, Federal Legislation, Students with Disabilities, Public Education, Individualized Education Programs, Tuition, Private Schools, Court Litigation, Credit (Finance), Special Education, Costs
Geographic Terms: New York (New York)
Laws, Policies and Program Identifiers: Individuals with Disabilities Education Act
Abstract: New York City's special-education system looks very different today from the way it did a decade ago. For the 2026 fiscal year, 2.15% of the Department of Education's entire budget was approved for "Carter-case" tuition reimbursement. Originally meant as a safeguard for students denied a Free Appropriate Public Education (FAPE), the Carter framework has expanded far beyond its intended purpose. Policy decisions such as the shift to settling previously won cases and reducing annual FAPE adjudications have allowed private placements to continue year after year without determining whether the district can meet students' needs in NYC. As filings increased, the city's spending on tuition reimbursement also increased significantly, even as outcomes for many private programs remain unknown. NYC's experience serves as a warning for states and large districts nationwide. With shifting more authority to states, NYC shows how deviations from the annual accountability structure of the Individuals with Disabilities Education Act (IDEA) can reshape incentives, obscure program quality, and create inequities in access to services. Reassessing Carter cases in NYC is essential to restore IDEA's accountability structure, rebuild the nation's largest public school system's capacity, and ensure that students receive appropriate services in their least restrictive environment (LRE), without relying on litigation.
Abstractor: ERIC
Entry Date: 2026
Accession Number: ED679657
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  Data: New York City's special-education system looks very different today from the way it did a decade ago. For the 2026 fiscal year, 2.15% of the Department of Education's entire budget was approved for "Carter-case" tuition reimbursement. Originally meant as a safeguard for students denied a Free Appropriate Public Education (FAPE), the Carter framework has expanded far beyond its intended purpose. Policy decisions such as the shift to settling previously won cases and reducing annual FAPE adjudications have allowed private placements to continue year after year without determining whether the district can meet students' needs in NYC. As filings increased, the city's spending on tuition reimbursement also increased significantly, even as outcomes for many private programs remain unknown. NYC's experience serves as a warning for states and large districts nationwide. With shifting more authority to states, NYC shows how deviations from the annual accountability structure of the Individuals with Disabilities Education Act (IDEA) can reshape incentives, obscure program quality, and create inequities in access to services. Reassessing Carter cases in NYC is essential to restore IDEA's accountability structure, rebuild the nation's largest public school system's capacity, and ensure that students receive appropriate services in their least restrictive environment (LRE), without relying on litigation.
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      – SubjectFull: Special Education
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      – SubjectFull: New York (New York)
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